Self-Regulatory Organizations; LCH SA; Order Approving Proposed Rule Change Relating to Amendments to CDSClear Reference Guide To Allow Index Basis Packages Margining, 947-949 [2020-00062]
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Federal Register / Vol. 85, No. 5 / Wednesday, January 8, 2020 / Notices
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January 29, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.36
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–00061 Filed 1–7–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–87881; File No. SR–LCH
SA–2019–009]
Self-Regulatory Organizations; LCH
SA; Order Approving Proposed Rule
Change Relating to Amendments to
CDSClear Reference Guide To Allow
Index Basis Packages Margining
jbell on DSKJLSW7X2PROD with NOTICES
January 2, 2020.
I. Introduction
On October 29, 2019, Banque Centrale
de Compensation, which conducts
business under the name LCH SA (‘‘LCH
SA’’ or ‘‘CDSClear’’), filed with the
Securities and Exchange Commission
(‘‘Commission’’) pursuant to Section
19(b)(1) of the Securities Exchange Act
36 17
CFR 200.30–3(a)(12).
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of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder 2 a proposed rule change
relating to amendments to the CDSClear
Reference Guide (the ‘‘CDSClear Risk
Methodology’’) to allow Index Basis
Packages margining. The proposed rule
change was published for comment in
the Federal Register on November 19,
2019.3 The Commission did not receive
comments regarding the proposed rule
change. For the reasons discussed
below, the Commission is approving the
proposed rule change.
II. Description of the Proposed Rule
Change
LCH SA is proposing to amend its
CDSClear Risk Methodology in order to
allow Index Basis Packages margining as
a single instrument.4 LCH SA CDSClear
currently clears CDS on a number of
indices such as iTraxx Main, iTraxx
Cross-over, iTraxx Senior Financials as
well as all the Single Name constituents
of these indices. Indices and their
constituents are currently managed and
margined as independent instruments.
However, market participants may
execute Index Basis Packages consisting
of an Index CDS trade and individual
Single Name CDS trades on each of the
reference entities constituents of such
Index perfectly offsetting the Index.
A transaction would need to satisfy
the following criteria to constitute an
Index Basis Package:
• The package is constituted of an
Index CDS and Single Name CDS on all
the entities constituting the index;
• The position (Long/Short) on the
Index offsets the positions on the Single
Names (Short/Long);
• The notional of the Index and
across all the Singles Names match
exactly;
• All the Single Names CDS trades
have the same currency, coupon, and
maturity as constituents of the Index
CDS; and
• All the Single Name CDS trades
have the same Seniority, ISDA
Definition and Restructuring Clause as
constituents of the Index CDS.
Clearing Members and/or Clients
would be required to identify all trades
being part of an Index Basis Package and
to notify LCH SA CDSClear. CDSClear
would then perform controls to ensure
all principles and requirements stated
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Self-Regulatory Organizations; LCH SA; Notice
of Filing of Proposed Rule Change Relating to
Amendments to CDSClear Reference Guide To
Allow Index Basis Packages Margining; Exchange
Act Release No. 87522 (Nov. 13, 2019); 84 FR 63912
(Nov. 19, 2019) (‘‘Notice’’).
4 The description herein is substantially
excerpted from the Notice, 84 FR 63912.
2 17
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Frm 00075
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947
above for qualifying the trades as an
Index Basis Package are satisfied and
would flag them with a common ID
number. These trades would continue to
be margined as different trades until
LCH SA completes these controls and
confirms the qualification as an Index
Basis Package.
Once an Index Basis Package is
validated as complete, the margin
enhancement proposed in the current
rule change would then be applied as
part of the overnight margin calculation.
In order to ensure that the trades
continue to meet the criteria of an Index
Basis Package, controls would be
performed every day at the start of the
overnight batch process.
Index Basis Packages identified and
flagged as such would be excluded from
compression runs with the rest of the
portfolio in order to avoid breaking any
packages.
Index Basis Packages could be unflagged as such at the Clearing Member
and/or Client’s request. The Index CDS
and the Single Name CDS would then
be treated and margined separately as
per the current framework.
In case of a Clearing Member’s
default, CDSClear would have the
ability to liquidate Index Basis Packages
in a dedicated auction should it be
advised to do so by the Default
Management Group in order to
minimize the liquidation costs.
A. Proposed Changes to CDSClear Risk
Methodology
In order to take into account the
specific risk created by Index Basis
Packages positions, LCH SA proposes to
amend the calculation of the Spread
Margin and the calculation of the
Liquidity Charge Margin as described in
its Reference Guide, CDSClear Margin
Framework.
1. Spread Margin
LCH SA CDSClear currently considers
an Index Basis Package as multiple
instruments in the calculation of its
Spread Margin. In accordance with the
portfolio margining requirements under
Article 27 of Commission Delegated
Regulation (EU) No 153/2013 5 (the
‘‘RTS’’), LCH SA CDSClear applies a cap
of 80% to the possible margin offsets
reduction. Therefore, the Spread Margin
of an Index Basis Package is calculated
as the maximum between the expected
shortfall of the package and 20% of the
sum of the expected shortfalls
5 See https://eur-lex.europa.eu/LexUriServ/
LexUriServ.do?uri=OJ:L:2013:052:
0041:0074:EN:PDF.
E:\FR\FM\08JAN1.SGM
08JAN1
948
Federal Register / Vol. 85, No. 5 / Wednesday, January 8, 2020 / Notices
calculated for each components of the
package.
CDSClear believes that this does not
appropriately reflect the actual risk of
an Index Basis Package meeting the
criteria stated above, so it is proposing
to amend its CDSClear Risk
Methodology in order to consider Index
Basis Packages identified as such as a
single instrument when calculating the
amount of margins required. In
particular, the 80% cap on offsets
between the components of the Index
Basis Package would not be applied in
the calculation of the Spread Margin,
but would be maintained between an
Index Basis Package and all the other
positions in the portfolio. This may
result in a lower amount of margin
being collected on an Index Basis
Package.
In the opinion published in April
2017 6 and clarifying the application of
Article 27 of the RTS, the European
Securities and Market Authority
(‘‘ESMA’’), acknowledges the low level
of risk presented by a package
consisting of a future on an index and
futures on each of the constituents of
the index and allows a CCP to
acknowledge margin reduction in excess
of 80% in this specific case. This
proposal acknowledges this position.
2. Liquidity Charge Margin
Considering that an Index Basis
Package would likely be sold off in a
dedicated auction in case of default of
a Clearing Member, LCH SA also
proposes to amend the calculation of the
Liquidity Charge Margin described in
the CDSClear Risk Methodology in order
to better reflect the actual cost it would
incur when liquidating an Index Basis
Package. CDSClear proposes to charge a
specific bid/ask spread for each Index
family underlying an Index Basis
Package identified as such rather than
use the current Liquidity Charge Margin
algorithm based on charging bid/ask
spreads for each individual component
in the package taken independently.
The current Liquidity Charge Margin
methodology would nevertheless
remain in the calculation specific to
Index Basis Packages identified as such
by acting as a cap to the new calculation
method. Because the bid/ask spread
may be smaller, a lower amount of this
category of margin could be collected.
jbell on DSKJLSW7X2PROD with NOTICES
3. Other Exclusions
Finally, Index Basis Packages flagged
as such would be excluded from the
Recovery Risk, Interest Risk, or Wrong
Way Risk Margin calculations as by
construction Index Basis Packages are
immune to the risks these margins aim
at capturing.
III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act directs
the Commission to approve a proposed
rule change of a self-regulatory
organization if it finds that such
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to such organization.7 For the
reasons given below, the Commission
finds that the proposed rule change is
consistent with Section 17A(b)(3)(F) of
the Act 8 and Rules 17Ad–22(e)(6)(i) and
(iii) thereunder.9
A. Consistency With Section
17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act
requires, among other things, that the
rules of LCH SA be designed to promote
the prompt and accurate clearance and
settlement of securities transactions
and, to the extent applicable, derivative
agreements, contracts, and transactions,
as well as to assure the safeguarding of
securities and funds which are in the
custody or control of LCH SA or for
which it is responsible, and, in general,
to protect investors and the public
interest.10 As discussed above, the
proposed rule change would amend the
LCH SA CDSClear Risk Methodology to
allow Index Basis Packages margining as
a single instrument. As a result, LCH SA
would require a lesser amount of margin
to better reflect the lower risk of an
Index Basis Package compared to its
individual component instruments. The
Commission believes that these changes
would help ensure that LCH SA’s
margin requirements are commensurate
with the risks associated with clearing
Index Basis Packages, which in turn
would help ensure that LCH SA does
not require higher margins than
necessary and that Clearing Members
are able to effectively accumulate and
manage their financial resources.
Additionally, as noted above, LCH SA
also proposes to amend the calculation
of the Liquidity Charge Margin to better
reflect the actual cost it would incur
when liquidating an Index Basis
Package. Similarly, LCH SA proposes to
exclude Index Basis Packages from
inapplicable margin calculations such
as the Recovery Risk, Interest Risk, and
Wrong Way Risk Margin calculations
7 15
6 See
https://www.esma.europa.eu/sites/default/
files/library/esma70-708036281-18_opinion_on_
portfolio_margining.pdf.
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17:18 Jan 07, 2020
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U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
9 17 CFR 240.17Ad–22(e)(6)(i) and (iii).
10 15 U.S.C. 78q–1(b)(3)(F).
8 15
PO 00000
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because Index Basis Packages are not
subject to these risks. Similar to the
Spread Margins discussed above, the
Commission believes that these changes
would result in the collection of
margins more commensurate to the risks
associated with clearing Index Basis
Packages, which in turn would help
ensure that LCH SA does not require
higher margins than necessary and that
Clearing Members are able to effectively
accumulate and manage their financial
resources.
Taken together, the Commission
believes that these changes would
enhance the operation and effectiveness
of LCH SA’s margin collection system,
which is necessary to manage LCH SA’s
credit exposures to its Clearing
Members and the risks associated with
clearing security based swap-related
portfolios. By managing such exposures
and risks, LCH SA’s margin system
helps it avoid losses that could result
from the mismanagement of such credit
exposures and risks. Because such
losses could disrupt LCH SA’s ability to
promptly and accurately clear security
based swap transactions, by making the
above-described improvements to LCH
SA’s margin system, the proposed rule
change would help promote the prompt
and accurate clearance and settlement
os securities transactions. Similarly,
given that such losses could threaten
LCH SA’s access to securities and funds
in LCH SA’s control, by making the
above-described improvements to LCH
SA’s margin system, the Commission
believes that the proposed rule change
would help assure the safeguarding of
funds and securities which are in the
custody or control of LCH SA or for
which it is responsible. As noted above,
the Commission believes that these
changes also would help promote the
prudent and accurate accumulation and
management of financial resources by
both LCH SA and its Clearing Members.
Therefore, for the reasons stated
above, the Commission finds that the
proposed rule change would promote
the prompt and accurate clearance and
settlement of securities transactions,
assure the safeguarding of securities and
funds in LCH SA’s custody and control,
and, in general, protect investors and
the public interest, consistent with the
Section 17A(b)(3)(F) of the Act.11
B. Consistency With Rule 17Ad–
22(e)(6)(i)
Rule 17Ad–22(e)(6)(i) requires a
covered clearing agency that provides
central counterparty services to cover its
credit exposures to its participants by
establishing a risk-based margin system
11 15
E:\FR\FM\08JAN1.SGM
U.S.C. 78q–1(b)(3)(F).
08JAN1
Federal Register / Vol. 85, No. 5 / Wednesday, January 8, 2020 / Notices
jbell on DSKJLSW7X2PROD with NOTICES
that, as applicable, considers, and
produces margin levels commensurate
with, the risks and particular attributes
of each relevant product, portfolio, and
market.12 As noted above, LCH SA is
proposing to amend its CDSClear Risk
Methodology in order to allow Index
Basis Packages margining as a single
instrument as long as it meets the
criteria noted above. As a result, LCH
SA would amend its Spread Margin and
Liquidity Charge Margin so that these
margin requirements reflect a single
rather than separate trades, which may
result in a lower level of margin being
collected. The Commission believes that
these changes would help ensure that
LCH SA’s margin requirements are
commensurate with the risks associated
with clearing Index Basis Packages,
including by reflecting the lower risk
levels commensurate with Index Basis
Packages viewed as a single instrument,
as opposed to the individual component
instruments that make up the Index
Basis Package.
Therefore, for the above reasons the
Commission finds that the proposed
rule change is consistent with Rule
17Ad–22(e)(6)(i).13
C. Consistency With Rule 17Ad–
22(e)(6)(iii)
Rule 17Ad–22(e)(6)(iii) requires a
covered clearing agency that provides
central counterparty services to cover its
credit exposures to its participants by
establishing a risk-based margin system
that, as applicable, calculates margin
sufficient to cover its potential future
exposure to participants in the interval
between the last margin collection and
the close out of positions following a
participant default.14 As noted above,
with respect to the liquidity charge
margin, LCH SA proposes to charge a
specific bid/ask spread for each Index
family underlying an Index Basis
Package identified as such, rather than
use the current Liquidity Charge Margin
algorithm based on charging bid/ask
spreads for each individual component
in the package taken independently.
These proposed changes reflect that, in
the event of a Clearing Member default,
Index Basis Packages most likely would
be sold off as a single instrument in a
dedicated auction, rather than broken
apart into individual components with
each component instrument sold in an
independent auction. By helping to
ensure that the liquidity charge margin
applied to Index Basis Packages would
be commensurate with the risks
associated with clearing Index Basis
12 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(i).
14 17 CFR 240.17Ad–22(e)(6)(iii).
13 17
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17:18 Jan 07, 2020
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Packages, the Commission believes that
the proposed rule change would be
consistent with the requirement to have
margin sufficient to cover potential
future exposure to participants in the
interval between the last margin
collection and the close out of positions
following a participant default.
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act, and in
particular, with the requirements of
Section 17A(b)(3)(F) of the Act 15 and
Rules 17Ad–22(e)(6)(i) and (iii)
thereunder.16
It is therefore ordered pursuant to
Section 19(b)(2) of the Act 17 that the
proposed rule change (SR–LCH SA–
2019–009), be, and hereby is,
approved.18
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–00062 Filed 1–7–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meetings
Notice is hereby given,
pursuant to the provisions of the
Government in the Sunshine Act, Public
Law 94–409, that the Securities and
Exchange Commission Asset
Management Advisory Committee
(‘‘AMAC’’) will hold a public meeting
on Tuesday, January 14, 2020 at 9:00
a.m.
PLACE: The meeting will be held in
Multi-Purpose Room LL–006 at the
Commission’s headquarters, 100 F
Street NE, Washington, DC.
STATUS: The meeting will begin at 9:00
a.m. and will be open to the public.
Seating will be on a first-come, firstserved basis. Doors will open at 8:30
a.m. Visitors will be subject to security
checks. The meeting will be webcast on
the Commission’s website at
www.sec.gov.
MATTERS TO BE CONSIDERED: On
December 30, 2019, the Commission
TIME AND DATE:
15 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(6)(i) and (iii).
17 15 U.S.C. 78s(b)(2).
18 In approving the proposed rule change, the
Commission considered the proposal’s impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
19 17 CFR 200.30–3(a)(12).
16 17
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949
published notice of the Committee
meeting (Release No. 34–87835),
indicating that the meeting is open to
the public and inviting the public to
submit written comments to the
Committee. This Sunshine Act notice is
being issued because a majority of the
Commission may attend the meeting.
The meeting will include a discussion
of various aspects of the asset
management industry as well as
administrative items.
CONTACT PERSON FOR MORE INFORMATION:
For further information, please contact
Vanessa A. Countryman from the Office
of the Secretary at (202) 551–5400.
Dated: January 6, 2020.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020–00168 Filed 1–6–20; 4:15 pm]
BILLING CODE 8011–01–P
SURFACE TRANSPORTATION BOARD
[Docket No. FD 36372]
Union Pacific Railroad Company—
Temporary Trackage Rights
Exemption—BNSF Railway Company
Union Pacific Railroad Company
(UP), a Class I rail carrier, has filed a
verified notice of exemption under 49
CFR 1180.2(d)(8) for the acquisition of
temporary overhead trackage rights over
an approximately 51.7-mile rail line of
BNSF Railway Company (BNSF)
between milepost 579.3 near Mill Creek,
Okla., on BNSF’s Creek Subdivision and
milepost 631.0 near Joe Junction, Tex.,
on BNSF’s Madill Subdivision, pursuant
to the terms of a Temporary Trackage
Rights Agreement (Agreement).1
UP states that the purpose of the
temporary trackage rights is to permit it
to move empty and loaded unit ballast
trains solely for UP’s maintenance of
way projects. The Agreement provides
that the trackage rights are temporary in
nature and are scheduled to expire on
December 31, 2020.
The transaction may be consummated
on or after January 22, 2020, the
effective date of the exemption (30 days
after the verified notice was filed).
As a condition to this exemption, any
employees affected by the acquisition of
the temporary trackage rights will be
protected by the conditions imposed in
Norfolk & Western Railway—Trackage
Rights—Burlington Northern, Inc., 354
I.C.C. 605 (1978), as modified in
Mendocino Coast Railway—Lease &
Operate—California Western Railroad,
360 I.C.C. 653 (1980), and any
1 A copy of the Agreement was filed with the
verified notice.
E:\FR\FM\08JAN1.SGM
08JAN1
Agencies
[Federal Register Volume 85, Number 5 (Wednesday, January 8, 2020)]
[Notices]
[Pages 947-949]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-00062]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-87881; File No. SR-LCH SA-2019-009]
Self-Regulatory Organizations; LCH SA; Order Approving Proposed
Rule Change Relating to Amendments to CDSClear Reference Guide To Allow
Index Basis Packages Margining
January 2, 2020.
I. Introduction
On October 29, 2019, Banque Centrale de Compensation, which
conducts business under the name LCH SA (``LCH SA'' or ``CDSClear''),
filed with the Securities and Exchange Commission (``Commission'')
pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder \2\ a proposed rule change
relating to amendments to the CDSClear Reference Guide (the ``CDSClear
Risk Methodology'') to allow Index Basis Packages margining. The
proposed rule change was published for comment in the Federal Register
on November 19, 2019.\3\ The Commission did not receive comments
regarding the proposed rule change. For the reasons discussed below,
the Commission is approving the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Self-Regulatory Organizations; LCH SA; Notice of Filing of
Proposed Rule Change Relating to Amendments to CDSClear Reference
Guide To Allow Index Basis Packages Margining; Exchange Act Release
No. 87522 (Nov. 13, 2019); 84 FR 63912 (Nov. 19, 2019) (``Notice'').
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
LCH SA is proposing to amend its CDSClear Risk Methodology in order
to allow Index Basis Packages margining as a single instrument.\4\ LCH
SA CDSClear currently clears CDS on a number of indices such as iTraxx
Main, iTraxx Cross-over, iTraxx Senior Financials as well as all the
Single Name constituents of these indices. Indices and their
constituents are currently managed and margined as independent
instruments. However, market participants may execute Index Basis
Packages consisting of an Index CDS trade and individual Single Name
CDS trades on each of the reference entities constituents of such Index
perfectly offsetting the Index.
---------------------------------------------------------------------------
\4\ The description herein is substantially excerpted from the
Notice, 84 FR 63912.
---------------------------------------------------------------------------
A transaction would need to satisfy the following criteria to
constitute an Index Basis Package:
The package is constituted of an Index CDS and Single Name
CDS on all the entities constituting the index;
The position (Long/Short) on the Index offsets the
positions on the Single Names (Short/Long);
The notional of the Index and across all the Singles Names
match exactly;
All the Single Names CDS trades have the same currency,
coupon, and maturity as constituents of the Index CDS; and
All the Single Name CDS trades have the same Seniority,
ISDA Definition and Restructuring Clause as constituents of the Index
CDS.
Clearing Members and/or Clients would be required to identify all
trades being part of an Index Basis Package and to notify LCH SA
CDSClear. CDSClear would then perform controls to ensure all principles
and requirements stated above for qualifying the trades as an Index
Basis Package are satisfied and would flag them with a common ID
number. These trades would continue to be margined as different trades
until LCH SA completes these controls and confirms the qualification as
an Index Basis Package.
Once an Index Basis Package is validated as complete, the margin
enhancement proposed in the current rule change would then be applied
as part of the overnight margin calculation.
In order to ensure that the trades continue to meet the criteria of
an Index Basis Package, controls would be performed every day at the
start of the overnight batch process.
Index Basis Packages identified and flagged as such would be
excluded from compression runs with the rest of the portfolio in order
to avoid breaking any packages.
Index Basis Packages could be un-flagged as such at the Clearing
Member and/or Client's request. The Index CDS and the Single Name CDS
would then be treated and margined separately as per the current
framework.
In case of a Clearing Member's default, CDSClear would have the
ability to liquidate Index Basis Packages in a dedicated auction should
it be advised to do so by the Default Management Group in order to
minimize the liquidation costs.
A. Proposed Changes to CDSClear Risk Methodology
In order to take into account the specific risk created by Index
Basis Packages positions, LCH SA proposes to amend the calculation of
the Spread Margin and the calculation of the Liquidity Charge Margin as
described in its Reference Guide, CDSClear Margin Framework.
1. Spread Margin
LCH SA CDSClear currently considers an Index Basis Package as
multiple instruments in the calculation of its Spread Margin. In
accordance with the portfolio margining requirements under Article 27
of Commission Delegated Regulation (EU) No 153/2013 \5\ (the ``RTS''),
LCH SA CDSClear applies a cap of 80% to the possible margin offsets
reduction. Therefore, the Spread Margin of an Index Basis Package is
calculated as the maximum between the expected shortfall of the package
and 20% of the sum of the expected shortfalls
[[Page 948]]
calculated for each components of the package.
---------------------------------------------------------------------------
\5\ See https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:052:0041:0074:EN:PDF.
---------------------------------------------------------------------------
CDSClear believes that this does not appropriately reflect the
actual risk of an Index Basis Package meeting the criteria stated
above, so it is proposing to amend its CDSClear Risk Methodology in
order to consider Index Basis Packages identified as such as a single
instrument when calculating the amount of margins required. In
particular, the 80% cap on offsets between the components of the Index
Basis Package would not be applied in the calculation of the Spread
Margin, but would be maintained between an Index Basis Package and all
the other positions in the portfolio. This may result in a lower amount
of margin being collected on an Index Basis Package.
In the opinion published in April 2017 \6\ and clarifying the
application of Article 27 of the RTS, the European Securities and
Market Authority (``ESMA''), acknowledges the low level of risk
presented by a package consisting of a future on an index and futures
on each of the constituents of the index and allows a CCP to
acknowledge margin reduction in excess of 80% in this specific case.
This proposal acknowledges this position.
---------------------------------------------------------------------------
\6\ See https://www.esma.europa.eu/sites/default/files/library/esma70-708036281-18_opinion_on_portfolio_margining.pdf.
---------------------------------------------------------------------------
2. Liquidity Charge Margin
Considering that an Index Basis Package would likely be sold off in
a dedicated auction in case of default of a Clearing Member, LCH SA
also proposes to amend the calculation of the Liquidity Charge Margin
described in the CDSClear Risk Methodology in order to better reflect
the actual cost it would incur when liquidating an Index Basis Package.
CDSClear proposes to charge a specific bid/ask spread for each Index
family underlying an Index Basis Package identified as such rather than
use the current Liquidity Charge Margin algorithm based on charging
bid/ask spreads for each individual component in the package taken
independently. The current Liquidity Charge Margin methodology would
nevertheless remain in the calculation specific to Index Basis Packages
identified as such by acting as a cap to the new calculation method.
Because the bid/ask spread may be smaller, a lower amount of this
category of margin could be collected.
3. Other Exclusions
Finally, Index Basis Packages flagged as such would be excluded
from the Recovery Risk, Interest Risk, or Wrong Way Risk Margin
calculations as by construction Index Basis Packages are immune to the
risks these margins aim at capturing.
III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act directs the Commission to approve a
proposed rule change of a self-regulatory organization if it finds that
such proposed rule change is consistent with the requirements of the
Act and the rules and regulations thereunder applicable to such
organization.\7\ For the reasons given below, the Commission finds that
the proposed rule change is consistent with Section 17A(b)(3)(F) of the
Act \8\ and Rules 17Ad-22(e)(6)(i) and (iii) thereunder.\9\
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\7\ 15 U.S.C. 78s(b)(2)(C).
\8\ 15 U.S.C. 78q-1(b)(3)(F).
\9\ 17 CFR 240.17Ad-22(e)(6)(i) and (iii).
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A. Consistency With Section 17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act requires, among other things, that
the rules of LCH SA be designed to promote the prompt and accurate
clearance and settlement of securities transactions and, to the extent
applicable, derivative agreements, contracts, and transactions, as well
as to assure the safeguarding of securities and funds which are in the
custody or control of LCH SA or for which it is responsible, and, in
general, to protect investors and the public interest.\10\ As discussed
above, the proposed rule change would amend the LCH SA CDSClear Risk
Methodology to allow Index Basis Packages margining as a single
instrument. As a result, LCH SA would require a lesser amount of margin
to better reflect the lower risk of an Index Basis Package compared to
its individual component instruments. The Commission believes that
these changes would help ensure that LCH SA's margin requirements are
commensurate with the risks associated with clearing Index Basis
Packages, which in turn would help ensure that LCH SA does not require
higher margins than necessary and that Clearing Members are able to
effectively accumulate and manage their financial resources.
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\10\ 15 U.S.C. 78q-1(b)(3)(F).
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Additionally, as noted above, LCH SA also proposes to amend the
calculation of the Liquidity Charge Margin to better reflect the actual
cost it would incur when liquidating an Index Basis Package. Similarly,
LCH SA proposes to exclude Index Basis Packages from inapplicable
margin calculations such as the Recovery Risk, Interest Risk, and Wrong
Way Risk Margin calculations because Index Basis Packages are not
subject to these risks. Similar to the Spread Margins discussed above,
the Commission believes that these changes would result in the
collection of margins more commensurate to the risks associated with
clearing Index Basis Packages, which in turn would help ensure that LCH
SA does not require higher margins than necessary and that Clearing
Members are able to effectively accumulate and manage their financial
resources.
Taken together, the Commission believes that these changes would
enhance the operation and effectiveness of LCH SA's margin collection
system, which is necessary to manage LCH SA's credit exposures to its
Clearing Members and the risks associated with clearing security based
swap-related portfolios. By managing such exposures and risks, LCH SA's
margin system helps it avoid losses that could result from the
mismanagement of such credit exposures and risks. Because such losses
could disrupt LCH SA's ability to promptly and accurately clear
security based swap transactions, by making the above-described
improvements to LCH SA's margin system, the proposed rule change would
help promote the prompt and accurate clearance and settlement os
securities transactions. Similarly, given that such losses could
threaten LCH SA's access to securities and funds in LCH SA's control,
by making the above-described improvements to LCH SA's margin system,
the Commission believes that the proposed rule change would help assure
the safeguarding of funds and securities which are in the custody or
control of LCH SA or for which it is responsible. As noted above, the
Commission believes that these changes also would help promote the
prudent and accurate accumulation and management of financial resources
by both LCH SA and its Clearing Members.
Therefore, for the reasons stated above, the Commission finds that
the proposed rule change would promote the prompt and accurate
clearance and settlement of securities transactions, assure the
safeguarding of securities and funds in LCH SA's custody and control,
and, in general, protect investors and the public interest, consistent
with the Section 17A(b)(3)(F) of the Act.\11\
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\11\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency With Rule 17Ad-22(e)(6)(i)
Rule 17Ad-22(e)(6)(i) requires a covered clearing agency that
provides central counterparty services to cover its credit exposures to
its participants by establishing a risk-based margin system
[[Page 949]]
that, as applicable, considers, and produces margin levels commensurate
with, the risks and particular attributes of each relevant product,
portfolio, and market.\12\ As noted above, LCH SA is proposing to amend
its CDSClear Risk Methodology in order to allow Index Basis Packages
margining as a single instrument as long as it meets the criteria noted
above. As a result, LCH SA would amend its Spread Margin and Liquidity
Charge Margin so that these margin requirements reflect a single rather
than separate trades, which may result in a lower level of margin being
collected. The Commission believes that these changes would help ensure
that LCH SA's margin requirements are commensurate with the risks
associated with clearing Index Basis Packages, including by reflecting
the lower risk levels commensurate with Index Basis Packages viewed as
a single instrument, as opposed to the individual component instruments
that make up the Index Basis Package.
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\12\ 17 CFR 240.17Ad-22(e)(6)(i).
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Therefore, for the above reasons the Commission finds that the
proposed rule change is consistent with Rule 17Ad-22(e)(6)(i).\13\
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\13\ 17 CFR 240.17Ad-22(e)(6)(i).
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C. Consistency With Rule 17Ad-22(e)(6)(iii)
Rule 17Ad-22(e)(6)(iii) requires a covered clearing agency that
provides central counterparty services to cover its credit exposures to
its participants by establishing a risk-based margin system that, as
applicable, calculates margin sufficient to cover its potential future
exposure to participants in the interval between the last margin
collection and the close out of positions following a participant
default.\14\ As noted above, with respect to the liquidity charge
margin, LCH SA proposes to charge a specific bid/ask spread for each
Index family underlying an Index Basis Package identified as such,
rather than use the current Liquidity Charge Margin algorithm based on
charging bid/ask spreads for each individual component in the package
taken independently. These proposed changes reflect that, in the event
of a Clearing Member default, Index Basis Packages most likely would be
sold off as a single instrument in a dedicated auction, rather than
broken apart into individual components with each component instrument
sold in an independent auction. By helping to ensure that the liquidity
charge margin applied to Index Basis Packages would be commensurate
with the risks associated with clearing Index Basis Packages, the
Commission believes that the proposed rule change would be consistent
with the requirement to have margin sufficient to cover potential
future exposure to participants in the interval between the last margin
collection and the close out of positions following a participant
default.
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\14\ 17 CFR 240.17Ad-22(e)(6)(iii).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
proposed rule change is consistent with the requirements of the Act,
and in particular, with the requirements of Section 17A(b)(3)(F) of the
Act \15\ and Rules 17Ad-22(e)(6)(i) and (iii) thereunder.\16\
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\15\ 15 U.S.C. 78q-1(b)(3)(F).
\16\ 17 CFR 240.17Ad-22(e)(6)(i) and (iii).
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It is therefore ordered pursuant to Section 19(b)(2) of the Act
\17\ that the proposed rule change (SR-LCH SA-2019-009), be, and hereby
is, approved.\18\
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\17\ 15 U.S.C. 78s(b)(2).
\18\ In approving the proposed rule change, the Commission
considered the proposal's impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
\19\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\19\
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-00062 Filed 1-7-20; 8:45 am]
BILLING CODE 8011-01-P